ClickTrain Privacy Policy (Talent and Registered Users)

• Contact information: such as your name, email address, phone number and location (city/region).
• Professional information: details about your skills, experience, qualifications, certifications, portfolio, work history, salary expectations and availability.
• Preferences and job information: information about the type of roles you are interested in, desired working arrangements (e.g. full-time, part-time, hybrid, remote) and geographic preferences.
• Communications: any communications you send us, including feedback, enquiries and survey responses.
• Consents: your marketing preferences and cookie consent choices.
• Optional recruitment data: if you choose to participate in our recruitment process, you may provide additional information such as self-rated skills, a short profile video (hosted via api.video) and identity documents for right-to-work verification. These optional data are processed as described in our Recruitment & Skills Testing Policy.

• Device and usage data: IP address, browser type, device information and operating system.
• Site usage analytics: pages visited, time spent on pages, user journeys, referring/exit pages, error logs and other diagnostic data.
• Cookies and tracking technologies: small text files stored on your device. We use functional cookies to operate our Platform and analytics cookies to understand how it is used. We also use remarketing cookies to serve advertising to returning users who have consented to cookies. You can manage your preferences through our cookie banner.

• 1. Account creation and profile management: to set up your talent profile, enable you to update your details, and provide you with access to platform features (lawful basis: performance of a contract).
• 2. Matching you to opportunities: to assess your skills, experience, location and preferences and present your profile to agencies or employers seeking specialists. Matching may include automated ranking of candidates based on professional factors (see Section 5) and may consider optional recruitment data (e.g., video introductions, verified right-to-work status) if you provide them.
• 3. Providing services and support: to respond to enquiries, help you use our Platform, fulfil any requests you make and administer our relationship.
• 4. Marketing communications: if you opt-in to receive marketing, we will send you emails about our products and services or those of selected partners. You may withdraw consent at any time.
• 5. Analytics and service improvement: to analyse usage of our website and Platform, understand user behaviour, and improve our offerings.
• 6. Compliance, security and legal obligations: to comply with legal requirements, respond to law-enforcement requests, enforce our terms, protect against fraud and secure our systems. Data protection law requires that processing be "fair" and avoid unjustified adverse effects on individuals.
• 7. Other legitimate interests: for business administration, record keeping, training of our staff and internal audits. We will consider your interests and fundamental rights before relying on our legitimate interests.

• Contractual necessity: when you register and create a profile or sign up for our services, we process your data because it is necessary to perform our contract with you or to take steps at your request before entering into a contract.
• Consent: we rely on your consent to send you marketing communications and to use remarketing cookies. You may withdraw your consent at any time. We also rely on your consent to collect optional recruitment data such as your video and right-to-work verification.
• Legitimate interests: we process personal data for our legitimate interests, such as matching specialists to opportunities, improving our services, preventing fraud and ensuring security. We balance these interests against your rights and freedoms and will not process your data for activities where our interests are overridden by yours.
• Legal obligations: we may process your personal data to comply with applicable laws, including tax, accounting and employment laws.

• We use only job-relevant factors to rank candidates.
• Our independent assessment team manually evaluates skills tests and certifications, and human reviewers can adjust rankings before presenting candidates to agencies or employers.
• You may request human intervention or object to an automated decision affecting you.
• Our team monitors the algorithm’s outputs for unintentional bias and reviews the underlying training data to mitigate discrimination risk. The ICO notes that AI systems trained on unbalanced or discriminatory data may produce outputs which have discriminatory effects; we continuously review our processes to prevent this.

• With hiring agencies or employers: when you are matched to a role, we share relevant profile information: including your video and verified right-to-work status if you provide them for recruitment and evaluation purposes. We obtain your consent before submitting your profile.
• Independent assessment team: we share your name, test responses and profile video (where applicable) with our independent assessment team solely for the purpose of marking skills tests and verifying certifications. They do not use or share your personal data for any other purpose.
• Identity verification providers: we may share your identity documents or data with trusted providers (e.g., Veriff) to perform right-to-work checks. These providers process the data on our behalf and return only a verification status and reference number.
• Service providers: we use trusted third-party providers for hosting, analytics, communications, payment processing, security and other functions necessary to operate our Platform. These providers process data only on our instructions and under strict confidentiality obligations.
• Corporate affiliates: we may share data with our subsidiaries or associated companies as part of internal administration or in connection with a merger or acquisition.
• Legal and regulatory authorities: we may disclose personal data to public authorities when required by law or to protect our rights and the rights of others (e.g., fraud prevention or responding to lawful requests).
• Aggregated and anonymised data: we may share aggregated or anonymised analytics that does not identify you.

We do not sell, rent or trade your personal information.

• Account data: contact details, professional information and preferences are retained while your account is active. If you close your account, we will delete your personal data within a reasonable period unless retention is required by law or necessary to resolve disputes.
• Skills tests, assessments and recruitment data: retention periods are described in our Recruitment & Skills Testing Policy.
• Communications: we retain correspondence for as long as necessary to respond to you and for record keeping.
• Analytics and logs: data may be retained in anonymised or aggregated form for analytics and security purposes.
• Legal retention: we may retain certain information to comply with legal obligations, defend legal claims or enforce contracts.

• 1. Right of access: you can request a copy of the personal data we hold about you.
• 2. Right to rectification: you can ask us to correct inaccurate or incomplete personal data.
• 3. Right to erasure: you can request deletion of your personal data in certain circumstances.
• 4. Right to restrict processing: you can request that we restrict processing if you contest the accuracy of the data, the processing is unlawful, or you have objected.
• 5. Right to object: you can object to processing based on our legitimate interests or to direct marketing.
• 6. Right to withdraw consent: if processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing before the withdrawal.
• 7. Right to data portability: you can request the transfer of your personal data to another controller.
• 8. Right not to be subject to certain automated decision-making: you have the right to request human intervention and to contest decisions made solely by automated means if those decisions have legal or similarly significant effects on you.

To exercise your rights, please contact dpo@clicktrain.com. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if you believe your data has been mishandled.